COMPLIANCE CALENDAR
FEBRUARY
Get the HMDA data in by the end of the month - or sooner. Be sure to do a quality and edit check before sending in your data.
If HMDA is under control, review your BSA exempt list. This should be updated next month. Be sure you have time to give appropriate attention to account activity of exempt customers.
Remember to look at FinCEN's proposal to revise and simplify the form for designation of exempt persons. Comments are due by February 25.
Also, pull together a team to conduct an information security assessment. Look at requirements under BSA, G-L-B, the FACT Act, and any other requirements you can think of.
MARCH
Comments are due to the Federal Reserve on the Advance Notice of Proposed Rulemaking on Regulation Z rules affecting open end credit by March 28.
Update your BSA exemption list. Remember to study the account activity.
While working on your exemption list, review the quality of your customer risk assessments and due diligence. Be sure you meet your regulator's expectations.
If you encountered problems preparing your HMDA LAR, start now to prevent the same problems in your 2005 data.
Watch for updates to the FRB Official Staff Commentaries, especially for Regulation Z.
APRIL
It's Fair Housing month again. Schedule fair lending training and self-assessments for this month.
Do a readiness assessment on the FACT Act provisions that take effect on July 1, 2005. Train staff on identity theft flags and review procedures for obtaining and using credit reports.
Watch for other FACT Act rules if they haven't come out yet.
MAY
Privacy's anniversary date is coming up. Be sure your annual notices go out on time.
As a customer service, consider including identity theft information in your privacy mailing.
Copyright © 2005 Compliance Action. Originally appeared in Compliance Action, Vol. 10, No. 1, 1/05
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